Ella Baché Elsternwick

1.1 Hallas Trading Company Pty Limited ("Hallas") manufactures,
markets and distributes cosmetic products. Since circa 1954 it has
primarily been engaged in manufacturing and distributing Ella Baché
products through Ella Baché salons in Australia and New Zealand,
which it does under Licence from Ella Baché Inc. and others.

2.1 Hallas is bound by the Privacy Act 1988 and the National
Privacy Principles and deals with personal information in
accordance with such principles. This Privacy Policy has been
established in accordance with National Privacy Principle 5.1.

2.2 The National Privacy Principles can be obtained through the
website of the office of the Federal Privacy Commissioner (http://www.privacy.gov.au)

3. INFORMATION COLLECTED BY HALLASPersonal Information

What It Is Used For From salon owners, information such as name,
address of salon, telephone number, facsimile number, account
details, contract information and confidential business
information.

day to day business communications with salons

providing salon assistance· arranging meetings and
conferences

maintaining account records

providing salon contact details to members of the public

From the community, information such as names, contact details
and email addresses of members of the public who contact Hallas
with request for information or feedback

To respond to those requests To provide newsletters and
marketing information to members of the public including the
provision of ELLA enewsletters, virtual salons enewsletters and
David Jones virtual stores enewsletters. From other third parties
such as contractors who provide services to Hallas. * To
communicate and correspond with such persons.

4. HOW DOES HALLAS HANDLE PERSONAL
INFORMATION

Use and Disclosure of Information

4.1 We may use personal information collected from you for the
purpose of providing you with direct marketing material and
information upon your registering your details with us. However if
you wish to cease receiving any such information you may let us
know either by e-mail or by mail and your request will be actioned
within 5 working days.

4.2 Personal information may be disclosed to external
contractors but only to enable us to provide services to you. Such
contractors will be required to adopt and adhere to our Privacy
Policy.

4.3 Consistent with National Privacy Principle 2, Hallas will
only use or disclose personal information about an individual for a
purpose other than the primary purpose of collection (a secondary
purpose) if:

The secondary purpose is related to the primary purpose of
collection;

You would reasonably expect us to use or disclose the
information for the secondary purpose;

You have consented to the use or disclosure;

The use or disclosure is permitted or required under the
law;

We reasonably believe on health or public safety grounds that
the information should be used for another purpose.

It is otherwise permitted under the National Privacy
Principles.

Manner of collection

4.4 Hallas receives personal information from salons and other
third parties through direct communications with such persons in
the normal course of business. Hallas may collect personal
information about individuals from third parties but will only do
so in accordance with the National Privacy Principles.

Information collected on visiting our
website

4.5 When you look at this website, a record is made of your
visit and for the purpose of analysing and evaluating the
performance and operation of our website, the following information
is logged:

Your IP address;

The date and time of your visit to the site;

The pages you accessed and documents downloaded;

The previous site you have visited;

The type of browser you are using

How Hallas uses cookies

4.6 A "Cookie" is a small text file which is placed on your
computer by webpage servers. The purpose of a cookie is to help
analyse web traffic and may let the website know when you visit a
particular site. Cookies allow a web application to respond to you
as an individual. They can record information about your visit to
the site, allowing it to remember you next time you visit and
provide any relevant information to you. Cookies are also used to
enhance the secure use of websites.

4.7 Cookies can be stored in your hard drive ("persistent
cookies") or in memory ("session cookies"). A persistent cookie is
a cookie which will enable a continuing record to be kept of your
visits to the website. A session cookie is a cookie which is a
transient cookie and tracks your visits for a website session
only.

4.8 Hallas only uses session cookies to identify which pages of
the website are being used for a website session only. Upon closing
your browser the session cookie set by this website is destroyed
and no personal information is maintained. Hallas does not make any
attempt to identify users or their general browsing activities.

Data quality

4.9 Consistent with National Privacy Principle 3, Hallas is
committed to ensuring that personal information collected by Hallas
remains accurate, complete and up to date. In pursuit of this goal,
Hallas provides via its website, a facility for authorised users to
update relevant personal details.

Storage and data protection

4.10 Personal information is contained both in hard copy and
electronic format within the offices of Hallas. Personal
information stored electronically is maintained in a secure
environment.

4.11 The above records are only accessible to personnel of
Hallas who require access to enable them to perform their duties.
All personnel have signed Privacy and Confidentiality Agreements
binding them to comply with the National Privacy Principles.

Destruction of records

4.12 Hallas will destroy records relating to personal
information when such information is no longer necessary to be
retained within Hallas' records. Personal information will be
destroyed by shredding or other secure process.

Openess

4.13 Consistent with National Privacy Principle 5.2, Hallas will
upon request, inform a person generally about what information it
holds concerning that person and for what purpose such information
is held. With respect to gaining access to or correction of
records, please see paragraph 4.14 ("Access to records")

Access to records

4.14 Individuals may access personal information by writing to
the Privacy Compliance Officer of Hallas. No reasons have to be
provided for seeking access. Where Hallas holds information to
which a person is entitled to access, it will endeavour to provide
a suitable range of choices as to how access may be given.

4.15 If a person believes that information held by Hallas is
incorrect, incomplete or inaccurate they may request amendment of
that personal information. Hallas will consider if the information
requires amendment. If Hallas does not agree that there is any
ground for amendment it will, if the person seeking the amendment
requires, place with that person's personal information, a
statement from that person as to why the information is not
accurate or up to date.

5. COMPLAINTS PROCEDURE

5.1 Hallas is committed to providing those persons whose
personal information it holds, a fair and responsible system for
the handling of complaints concerning the collection, accuracy or
disclosure of personal information.

5.2 Hallas has a designated officer (the "Privacy Compliance
Officer") whose role includes dealing with complaints, concerns or
queries that individuals may have with respect to personal
information held by Hallas. Should you have any issues concerning
your personal information, those complaints should be addressed to
the Privacy Compliance Officer of Hallas (at the address referred
to in paragraph 1.2 of this Policy).

5.3 The Privacy Compliance Officer is empowered to deal with all
such complaints as expeditiously as possible through Hallas'
complaints handling process. However, if you feel that we have not
adequately dealt with your concerns you may refer the matter to
the